FINAL annuity provider reg comment letter

Walter Welsh Executive Vice President, Taxes & Retirement Security (202) 624-2157 t (202) 572-4795 f walterwelsh@acli.com Susan Luken Senior Counsel, Pensions (202) 624-2138 t (202) 572-4789 f susanluken@acli.com November 13, 2007 Filed Electronically Office of Regulations and Interpretations Employee Benefits Security Administration Room N–5669 U.S. Department of Labor 200 Constitution Avenue, N.W. Washington, DC 20210 Attn: Annuity Regulation Re: Proposed Regulation – Selection of Annuity Providers for Individual Account Plans Dear Sir or Madam: The American Council of Life Insurers ("ACLI") appreciates the opportunity to comment on the proposed regulation issued by the Department of Labor (the "Department") regarding the selection of annuity providers for the purpose of benefit distributions from individual account plans, published at 72 Fed. Reg. 52,021 (September 12, 2007) (the "Proposed Regulation"). The ACLI represents three hundred seventy-three (373) member companies, accounting for ninety-three (93) percent of the life insurance industry's total assets in the United States. In addition to life insurance and annuities, ACLI member companies offer pensions, including 401(k)s, long-term care insurance, disability income insurance and other retirement and financial protection products, as well as reinsurance. Life insurers are among the country's leaders in providing retirement security to American workers ...